Pulsar Components International, Inc. - Page 29

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             i.  Employer's Salary Policy As to All Employees                         
             Courts have considered salaries paid to other employees of a             
          business in deciding whether compensation is reasonable.                    
          Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. at 1159.              
          We look to this factor to determine whether the Officers were               
          compensated differently than petitioner's other employees merely            
          because of the Officers' status as shareholders.  Owensby &                 
          Kritikos, Inc. v. Commissioner, 819 F.2d at 1322-1323.  A                   
          reasonable, longstanding, and consistently applied compensation             
          plan, for example, is evidence that compensation is reasonable.             
          Elliotts, Inc. v. Commissioner, supra at 1247.                              
             Petitioner generally offered its employees an amount that, in            
          its board's judgment, was a competitive level of compensation               
          designed to secure and retain employees.  Petitioner paid its               
          sales and purchasing staff a base salary, commissions, and                  
          benefits.  Petitioner paid its other employees a salary, some               
          benefits, and an occasional bonus.  This factor favors neither              
          party.  We consider it neutral.                                             
             j.  Compensation Paid in Prior Years                                     
             An employer may deduct compensation paid to an employee in a             
          year although the employee performed the services in a prior                
          year.  Lucas v. Ox Fibre Brush Co., 281 U.S. 115, 119 (1930); see           
          also R.J. Nicoll Co. v. Commissioner, 59 T.C. 37, 50-51 (1972),             
          and the cases cited therein.  In order to do so, the employer               





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